Provider relief fund recipients have expressed confusion about the Department of Health & Human Services’ (HHS) publicized June 3, 2020 deadline for submitting certain tax and financial documentation. The confusion stemmed from the mismatch between the submission date and the attestation date. The risk of non-compliance with the June 3 deadline, even for providers that are not seeking additional funds, is, among others, triggering a potential recoupment action. On June 2, 2020, HHS issued the following clarification to its provider relief fund website:
ALERT: Providers need to take action by June 3, 2020. Providers must submit revenue information to the General Distribution Portal by June 3, 2020 to be considered for an additional payment from the Provider Relief Fund $20 billion General Distribution. Once providers submit their revenue information by June 3, 2020, if deemed qualified for additional payment, providers will then have 90 days from receipt of payment of the additional General Distribution funds to agree to the program Terms and Conditions.
(emphasis added). Based on the updated statement, it appears the June 3, 2020 deadline must be met only if providers received funds from the initial $30 billion disbursement and want to be considered for additional provider relief funds. Otherwise, providers should submit tax and financial documentation when they submit their attestation for the funds. The deadline for the attestation was recently extended to 90 days from receipt of funds.
For more information, please contact Hedy S. Rubinger or Alexander B. Foster.